Lessons Learned by an Oilfield Services Company in the Development of a Chemical Management System Toward Compliance with REACH

Abstract

On 1 June 2007, a new era of chemical regulations began. The European Union (EU) consolidated approximately 40 pieces of existing chemical legislation and transformed them into one comprehensive chemical regulation called REACH (Registration, Evaluation, Authorisation, and Restriction of Chemicals). This new approach to chemical management puts a greater burden on importers and manufacturers. It also changes how the oilfield and gas service industry conducts business in not only the EU but also in the global chemical products marketplace. For the oilfield and gas service industry, REACH poses significant challenges requiring the reexamination of current practices in the import and manufacturing of oilfield service products. The regulatory requirements go far beyond the function of the HSE manager. Continuous interaction between the business functions of supply chain, logistics, HSE, IT, trade control, product development, sales and marketing, legal, and field operations is imperative to comply with this complicated, vastly encompassing piece of legislation. Lessons learned during the pre-registration phase in 2008 offered a clearer perspective on future registration requirements under REACH and have necessitated the reevaluation of chemical formulations in oilfield service products. This effort also requires the development and implementation of an ongoing chemical management system that continuously tracks the import and manufacturing of chemical substances found in numerous oilfield service products. Additional variables further complicate this tracking of substances are legal entities, management of chemical suppliers, communication between internal databases, and protection of confidential business information. This paper shares the process currently being developed and implemented by an oilfield services company towards compliance with REACH.